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UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF KENTUCKY IN RE: ) ) ) ) ) Debtor(s) ) _______________________________________)

CASE NO.

MOTION TO STRIP OFF A JUNIOR LIEN Debtor(s), by counsel, hereby moves the Court to strip off and avoid the lien of creditor, , on the following described property:

Debtor(s) intends to strip off creditor, , lien and to treat said creditor's claim as unsecured. Debtor(s) states that the basis for the lien stripping is lack of equity in the encum bered property and in supportof said Motion subm the following inform its ation: 1.The amount of the claim which the lien secures is $ 2.The above mentioned lien is a lien.

3.Debtor submits the following information on the value of the property: A). Fair Market Value: $ B). Value listed in Schedules: $
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C). Value according to records of County Property Valuation Administration: $ D). Purchase Price: $ E). Date of Purchase: F). Appraised Value (if recently appraised): $ G). Senior mortgages or liens on the property and their amount:

4. The trustee has not

abandoned the property. in said property.

5. The debtor(s) does/does not claim an exemption of $

6. The lien held by the creditor im pairs the exemption of the debtor in the property described in the motion.

WHEREFORE, the debtor moves the Court to or er the lien stripped off, avoided, the claim d treated as unsecured, and for such other relief as may be entitled. *Any Motion to Strip Off a Junior Lien filed after the entry of an Order of Confirm ation MUST provide information in both the Motion and proposed Order as to how the plan and entered Order of Confirmation will be modified if the creditor's lien is stripped of and the claim thereafter f treated as unsecured. Attorney for Debtor(s)

Address Phone Number

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CERTIFICATE OF SERVICE I certify that a copy of this Motion was served upon, this day of , 20 .

Attorney for Debtor(s)

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UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF KENTUCKY IN RE:

) ) ) ) Debtor(s) ) _____________________________________________ )

CASE NO.

ORDER

This matter having come before the Court on the Motion by debtor(s) to Strip Off a Junior Lien and the Court being sufficiently advised, IT IS HEREBY ORDERED that the junior lien of creditor, in the property described as ,

is, STRIPPED OFF, and shall be treated as an UNSECURED claim under the Chapter 13 case. Should the debtor(s) complete their Chapter 13 plan and receive a discharge, the property will vest in the debtor(s) free and clear of this lien. Should the debto(s) fail to com r plete the plan and receive a discharge, upon the dism issal of the ba nkruptcy case any lien stri ped off and avoided will p be reinstated pursua nt to § 349 (b)(1)(C) of the Bankruptcy Code. Likewise, should the case be converted to Chapter 7, any lien stripped off will also be reinstated

Tendered by:

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